Disruptive Actors and Normative Expansion: Post-AI Act Governance in the European Union
نویسندگان
1 Department of Regional Studies, Faculty of Law and Political Science, University of Tehran, Tehran, Iran.
2 Department of Regional Studies, Faculty of Law and Political Science, University of Tehran, Tehran, Iran.
doi
10.22034/irfa.2025.548669.1304چکیده
This article reconceptualizes the European Union's Artificial Intelligence Act (AIA) as a catalyst for recursive governance, rather than a static legal instrument. While existing scholarship has examined regulatory overlaps with the General Data Protection Regulation (GDPR), particularly regarding high-risk AI systems and compliance burdens, it has largely overlooked how the AIA reshapes the broader governance ecosystem. The research asks: How do peripheral and non-formally embedded actors influence the trajectory of AI governance in the EU following the AIA's adoption? The central hypothesis is that disruptive actors—including the European Data Protection Board (EDPB), national regulators, and regional infrastructure initiatives—reconfigure post-AI Act governance by injecting citizen-centric accountability and expanding regulatory norms beyond the Act’s formal legal architecture. Empirical analysis of institutional consolidation (AI Office and AI Board), Member State innovation (Spain's ALIA, Barcelona AI Factory), and strategic interventions by non-embedded bodies (EDPB) demonstrates how legal codification activates multi-scalar feedback loops and pluralistic norm expansion. The article contributes to the experimentalist governance literature by showing that post-legislative regulation is shaped by infrastructural experimentation, normative turbulence, and strategic behavior at the margins. The EU's AI regime emerges as a dynamic system—where law, infrastructure, and contestation co-evolve in real time.